Equipment containing refrigerant fluids: what are the regulatory developments?

The regulations on refrigerants are evolving. New decrees set alarm thresholds for leaks, limit the use of non-hermetic equipment, and update intervention forms.

Marie Faucon
Consultante HSE
Publication : 
12.09.2017
Table of Contents
Example H2
Request a demo

Please note: This article concerns French legislation. The requirements described may not apply in other countries.

‍

The refrigerants (e.g., R134a, R407c, R410a) are used in refrigeration and air conditioning equipment such as chillers, air conditioners, or heat pumps. These fluids are responsible for certain greenhouse gases (GHGs). With the aim of controlling and reducing emissions of these GHGs, regulations are becoming increasingly stringent regarding the management of refrigerants.

In this context, a decree dated February 29, 2016, sets the rules for their management and the equipment containing them (equipment leak checks, fluid transfer procedures, content and usage of the intervention form, etc.). Since that date, 4 decrees have amended it (in July and December 2016, then in March and April 2017). In this article, we will review the main changes introduced by these 4 decrees.

Changes related to refrigerant leak detectors (July 2016)

Reminder: a leak detector is a permanent device that analyzes at least one of the following parameters: pressure, temperature, compressor current, liquid levels, or the volume of the recharged quantity. It is connected to an alarm that informs the operator of equipment containing refrigerants of any detected leak.

In July 2016, the alarm trigger threshold was modified, and deadlines for refrigerant leak detection using direct measurement methods were introduced.

‍

New version of CERFA form 15497 (December 2016)

Reminder: an intervention form must be completed by the operator (the service provider) for each operation involving the handling of refrigerants performed on equipment. Cerfa 15497(1) specifies the form template to be used in most cases (2). This Cerfa also serves as a Hazardous Waste Tracking Slip (BSD) for fluid disposal, regardless of the quantity of fluid in the equipment and for all activity categories.(2).

In December 2016, version 2 of CERFA form 15497 was published. It has been in use since December 30, 2016. This new version allows for:

  • the alignment of intervals (including the concept of less than or equal to) defining regulatory leak check periods with those defined in the decree of February 29, 2016,
  • the ability to specify a UN code and an ADR designation for refrigerant waste different from those for the general case,
  • the color-coding of sections to be completed depending on whether it concerns an intervention on equipment and/or an operation to evacuate refrigerants from the equipment for treatment in an authorized facility.
  • the integration of new appendices to account for the following two scenarios:

‍

A copy of the BSD must be returned within one month by the waste treatment facility, once the treatment is completed:

  • to the equipment owner, in cases where waste shipment occurred without collective collection,
  • to the collector (operator/service provider) in case of small quantity collection, via the use of Annex I.

Non-mandatory nature of standards for conducting leak checks (March 207)

The standards cited for leak checks concern operators holding a certificate of capacity who perform these checks (who may be service providers or part of your staff).

References to these standards have been reformulated. Henceforth, these standards are cited as examples. Their implementation is no longer mandatory but can be a means of meeting the requirements set by the decree regarding the performance of leak checks.

Limitation on the Operating Time of Leaking Equipment (April 2017)

The use of equipment containing fluorinated greenhouse gases, on which a leak was detected during a leak check, is now limited to 4 working days. Within this period:

  • either measures are implemented to stop the leak;
  • or the equipment is shut down and then drained by an operator holding a certificate of competence.

The equipment can only be put back into service after the leak has been repaired. If the equipment consists of multiple circuits, circuits or parts of circuits where no leak has been detected may remain in service. These obligations do not apply if shutting down the equipment is likely to compromise the safety or operational security of ICPE (Installations Classified for Environmental Protection) or basic nuclear installations. In this case, the equipment cannot be recharged with refrigerant until it has been repaired.

Our advice for equipment containing refrigerants

If you own equipment containing refrigerants (e.g., R134a, R407c, R410a), these changes must be taken into account in the management of this equipment, particularly for leak checks, in the event of refrigerant leaks, or operations requiring refrigerant handling.

If you have implemented procedures or instructions, it may be useful to update them. Similarly, it may be beneficial to discuss with your service provider about these new developments and their implementation concerning your equipment.

(1) Definition of Cerfa 15497: "Intervention Sheet / Tracking slip for hazardous waste for operations requiring the handling of refrigerants performed on equipment"

(2) This Cerfa 15497 form is to be used if the intervention falls under a Category I, II, III, or IV activity. It serves as a BSD for all categories, including Category V.

The activity categories are defined by the decree of June 30, 2008:

  • Category I: Leakage control, maintenance and servicing, assembly, commissioning, and fluid recovery from all refrigeration, air conditioning, and heat pump equipment.
  • Category II: Maintenance and servicing, assembly, commissioning, fluid recovery from refrigeration, air conditioning, and heat pump equipment containing less than 2 kg of refrigerant fluid, and leakage control of refrigeration, air conditioning, and heat pump equipment, air conditioning, and heat pump equipment.
  • Category III: Fluid recovery from refrigeration, air conditioning, and heat pump equipment containing less than 2 kg of refrigerant fluid;
  • Category IV: Leakage control of refrigeration, air conditioning, and heat pump equipment;
  • Category V: Leakage control, maintenance and servicing, assembly, commissioning, and fluid recovery from air conditioning systems of vehicles, machinery, and equipment referred to in Article R. 311-1 of the Highway Code.

‍